BAD OR WORSE?

The reaction to today’s production data release by the Ministry of Trade was an exercise in the spin process as the glass-half-full crowd took heart from a modest month-over-month sequential improvement to -9.37% coupled with a 4.2% decline in inventory levels –the thesis being that this was signaling a potential bottom.

We are unconvinced. Although declining inventories are clearly a positive signal for the drowning exporters, the data breakout showed little relief for the beleaguered automotive and consumer electronics sector as production declines in those spaces exceeded 50% on a year-over-year basis.

Our investment thesis in Japan remains unchanged: we still see Yen devaluation as the only potential driver for any near term recovery. Our short position in EWJ was initially caught flat footed as we put on the first leg in the face of the BOJ stimulus measures, which drove the Yen lower than we had anticipated. After selling a second leg into strength last week we are now close to flat on the position.

We continue to remain negative on Japan, and view it as a debt laden hostage to external demand. We will continue to adjust are portfolio opportunistically based on tactical factors, but our long term view remains decidedly glass-half-empty.

Andrew BarberDirector

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03/30/09 11:55 AM EDT

Where There’s Smoke… Notes for the Week Ending Friday, March 27, 2009

And The Winner Is…

Last week we asked readers to guess how soon the phrase “One Quadrillion Dollars” would appear in the mainstream media. With governments Left, Right and Center tossing trillions about like panties at a fraternity party, it was clearly only a matter of time before the sums would spin out of control.

Not forty-eight hours elapsed, but the Wall Street Journal (Wednesday 25 March) OpEd page ran “Toxic Assets Were Hidden Assets,” by Hernando de Soto, in which the following appears: “… aggressive financiers have manufactured what the Bank for International Settlements estimates to be $1 quadrillion worth of new derivatives….”

Speaking of money, the media is now joking “A trillion here, a trillion there…” but unlike Senator Dirksen, we are no longer talking about real money. Money is a contract based upon the consensus value of a basket of real items. The Gold Standard, long since abandoned, merely designated the single most useless component of the basket as a proxy for coal, oil, timber, agriculture, and the other assorted hard resources that keep the world turning. In today’s global Consensus of Confusion even the value of value is in question.

Since in God we no longer trust, the dollar’s stability is rooted in what accountants call Goodwill, and what the world knows as the Full Faith and Credit of the US Government. Now that the Faith needle is hovering at zero, and with Credit literally gone negative, there is neither Intrinsic nor Premium Value to the dollar.

One reaction to this situation is China’s proposal of a new global currency. When the Euro was first introduced, columnists at home and abroad wryly called it “Esperanto money”, and even a synthetic currency must seek its Full Faith and Credit legitimacy in some palpable measure: typically, the implicit backing of those nations who accept it in payment. IMF Special Drawing Rights, another synthetic store of value, are based on a basket of the US dollar, Pound Sterling, Euro, and Japanese Yen. Thus, the SDR looks like a set of hedged cross-trades of established currencies, rolled into a single contract.

Underlying China’s pronouncement is a heads-up call directed at the US. Like an artificially enhanced athlete on its last legs, the Dollar has had a few strong seasons. But now the fans know it is faltering, and its recent record has been marked with an asterisk. The scary thing is, there is no coming star on the horizon to take up when the champion is finally carried off the field.

The global push to immolating our children’s future is a terrifying substitute for thoughtful and responsible leadership. Governments are rushing to outdo one another in destroying their patrimony. Everywhere we turn we see Potlatch Economics. It is too late to say that it will end badly. It is already very, very bad.

The Talmud tells of the sage Honi the Circle-Maker, watching an elderly man planting a carob tree. “Old man,” asked Honi. “Why do you plant that sapling now? It will take seventy years for the carob to grow and bear fruit, and you will not be alive to enjoy it.”

“When I came into this world,” replied the man, “there were carob trees and I ate from them. Just as others, who were no longer alive, had planted carob saplings so that I might eat of their fruit, so I am planting this carob tree before I leave this world, so that there will be fruit for future generations.”

The Talmudic ideal is that we are all part of a community that extends from the creation of the world, down through history, and to the End Of Days. When President Obama speaks of The American People, he is reminding us that, unlike nations which derive their legitimacy from similarities of language, religion, skin color, eye shape, and common hatred for the people living in the next valley, America is a nation founded upon one basic ideal: that all people are equal, and that all have inalienable rights to Life, Liberty and the Pursuit of Happiness.

A society founded upon an ideal ignores that ideal at its peril. As long as the Wall Street professional considered himself a Customer’s Man, he knew where his duty lay, and his efforts contributed to the society – even if only to a defined social stratum. When he became a Financial Executive, the focus shifted from servicing the needs of the investment community, to building up his own Executive status. Executive Suite. Executive Perks. Executive Privilege.

Underlying the global crisis is the true crisis: the Crisis of Trust. A society that was not able to say No, that saw Gordon Gekko as a hero, is now shocked that “They” have let this happen to “Us”. Where, the world asks, has America’s Full Faith and Credit gone? It is a brave new world, to say the least, where America seeks to reassert its position of global dominance by doing everything it can to destroy its own credibility. Vocal and articulate critics of this program, like Nobelist Krugman, are still not able to come up with anything to top the very real wisdom that rises from the gutter. Not buying “trash with their cash” was one of Stu Travis’ golden rules. If Stu were sitting today beside Timothy Geithner – instead of gracing the heavenly pantheon, somewhere between Jesse Livermore and Carlo Ponzi – he would be blowing cigar smoke in Geithner’s face and telling him “Mark it up! Mark it up!” as Geithner & Co. lay the groundwork for the greatest principal trade in history.

Instead of providing for future generations, Potlatch Economics has put a Bizzarro twist on the Talmudic legend: “When I came into this world I inherited debt run up by those who had come before me. I am now running up enough debt to ensure that our children will be paying it off from now until the Coming of Messiah.”

Slouching Towards Wall Street

“SEC Pledges To Strengthen Its Oversight” reads the Financial times headline (March 27). Chairman Mary Schapiro has “… emphasized the importance of the SEC as the only government agency ‘responsible for both protecting investors and promoting capital formation.’” And suddenly it occurred to us – wasn’t this what went wrong at the NASD/NASDAQ, the New York Stock Exchange, Congress and Fannie Mae, and the entire brokerage and investment banking business?

When you are funded by the fees paid by the issuers who list on your exchange, when your members are the banks who package the deals, and the brokers who sell them, does it make sense that you should also self-regulate that activity?

Not a new argument. But timely.

The designation “Self-Regulatory Organization” (SRO) implies protection of the marketplace and the consumer. These organizations, funded by the entities they are charged with protecting us against, enjoy the privileged status of a quasi-governmental agency. They can limit, or suspend altogether, the ability of a company to raise capital. They can restrict, or cancel, the ability of a banking firm, or an individual, to earn a living in the industry. They charge membership dues and registration fees, and when they need to beef up their budgets, they levy fines. The one financial area where they have a poor track record is in preventing investor losses, and in compensating investors who were cheated.

Suffice it to say that we have conflicted regulators to oversee a conflicted business. The conflict-driven Wall Street business model will not change any time soon. Now, with Secretary Geithner making a push to become the master Regulator, we are truly entering the Twilight Zone of market instability.

In a hyper-hyperbole worthy of the moment, Bill Gross, founder of fixed-income management giant Pimco, said of Secretary Geithner’s public-private partnership proposal, “This is perhaps the first win/win/win policy to be put on the table and it should be welcomed enthusiastically.”

Three “wins” sounds downright desperate to us.

What assurances can Treasury offer the private investors, in addition to asking the Private side of the Partnership to put up only five percent of the cost of the transaction, while taxpayer dollars to cover the risk on the rest? Now, in case we are worried that market regulations may trip up our exit strategy, Mr. Geithner is taking control of the regulators as well.

Let it not be overlooked that, for the private investors to get out of these investments, they will ultimately have to sell them to someone. Large private equity firms have announced their interest in floating toxic assets mutual funds, and are looking into partnership structures to permit them to package toxic assets into what will essentially become long-term hedge funds for sophisticated investors.

We can just imagine how difficult these transactions might become if market regulators got involved, what with issues of disclosure and valuation.

Mr. Geithner is now out to arrogate to himself the control of the whole ball of wax. Cloaked as the power to drag bankers into the woodshed if they don’t toe the line, Geithner is making a play to control all regulation. The notion of creating one single global regulator – personally overseen by Mr. Geithner – is right out of the pages of Kurt Vonnegut. It used to be the job of the free markets to decide which firms succeed and fail, and under what circumstances. The freedom to make horrid mistakes and to be clobbered as a consequence is one of the great strengths underlying American Capitalism. It’s that “Pursuit of Happiness” thing. Capitalism is supposed to guarantee us only the Pursuit, not the Happiness.

To be sure, there is much to criticize in the current regulatory structure. The SEC granted the banks loosened risk parameters – giving them the ability to leverage 33 to one. In return, the SEC demanded – and after long and hard-fought negotiations, finally won – nothing more than permission to audit the firms it is charged with regulating. Of such capitulations are market implosions made.

The rules that get in the way of the Private Partners stand to be done away with. Hiding behind the highly orchestrated attack on mark to market accounting is the Trojan Horse of the Private Public Investment Partnership. How are private equity partnerships going to convince their wealthy limited partners to invest in a new hedge fund, made up of the Government’s raw sewage, when their investment – like a used jalopy – will decline precipitously in value the moment it is driven off the lot?

The ability of the promoter of a partnership to, itself, determine the value of that partnership’s portfolio is key to attracting investor dollars. The other key is the ability to dictate the exit strategy.

Mark To Market accounting is now being challenged on the notion that it forces institutions to mark portfolios down to distressed, or forced sale prices. We recognize that disasters are not everyday occurrences. But risk management tools fail if they do not protect against the outlier event. It is precisely the fire sale scenario that no one ever predicted would come, that we are facing today, and that mark To Market accounting was designed, at least in part, to address.

As has been observed – by James Chanos, for example (Wall Street Journal OpEd page, 24 March, “We Need Honest Accounting”) the assets subject to possible material revaluation under MTM represent relatively small percentages of most institutions’ holdings. But without a transactional market in the underlying assets, it is likely that 100% of the portfolios of the PPIP would be subject to MTM revaluation.

No one seems to have made this connection. Mr. Geithner’s push to become the Commander In Chief of market regulation could put him in a position to tell the SEC “hands off” when the PPIP packages its assets for sale, and when it starts selling off its portfolios.

Of course, many things would have to transpire before that happens. Not the least of which, the PPIP will have to find enough private sector interest to launch successfully. And then there’s always that Messiah thing…

A Safe Bet

ETF investors can breathe easy.

We have raised our concerns and questions about the ETF marketplace on more than one occasion. There appear to be several areas of potential regulatory concern, including the whipsaw effect that ETF creations and redemptions often have on underlying equities; the disparity between non-contemporaneous trading in the ETF and underlying commodity markets; the possibility of ETFs being hit with speculative restrictions under proposed new legislation, and the notion that, as ETF managers come to dominate sectors of the market, they will be seen as effectively dominating and controlling those sectors.

The good news is in: Goldman Sachs is said to be putting together a bid for Barclays’ iShares unit, one of the world’s leading creators of ETFs. ETF market participants should get a confidence boost if the Goldman purchase goes through. Goldman Sachs’ entanglement in the US government is perhaps the greatest concentration of influence and power coming from one organization since the Masons.

For those who need clarification, fifteen US presidents, 19 Vice Presidents have been masons. By some counts, at various periods during the early and mid-1900’s, as many as 2/3 of the members of Congress have been Masons.

In a story that no one else seems to think is related, Goldman announced its intention to repay the $10 billion in TARP money it has taken in. One of the foundation points of the TARP was getting all the banks to play by the same rules. But Goldman has always made its own rules, and has the ongoing success to show for it.

The Financial Times reports (24 March, “Goldman Working on iShares Bid”) that the Barclays unit could fetch as much as $6.5 billion. It goes on to say “The possible Goldman bid would be made by the bank, not its $20bn Principal Investment private equity fund, which manages money on behalf of third-party and employee investors.”

Goldman, the bank, which holds $10 billion in TARP money, will be subject to increased transparency requirements under Secretary Geithner’s upcoming “Stress Testing” program. Now Goldman has announced its intention to repay that money, and it has control over a $20 billion private fund. We would not be surprised to see a self-dealt bridge loan that would take Goldman out from under the microscope, giving it free rein to roam the markets while its competitors are being tied up in Secretary Geithner’s multicolored bureaucratic tape.

Say what you will about Goldman Sachs, they certainly understand power. With control of everything from the US Treasury, to the State of New Jersey, to the Bank of Canada, and well beyond, Goldman continues to dominate the globe. Hank Paulson showed himself a passed master of the Art of the Deal. Cutting through the numbing detail, he told members of Congress there would be an abrupt economic meltdown resulting in martial law if they failed to pass the TARP. That got their attention. And as AIG’s recently disclosed payouts to counterparties makes clear, Lloyd Blankfein is calling the shots every bit as much as Secretary Geithner. America was founded on Masonic principles. Let us pray it will not be destroyed on the principles of Goldman Sachs.

J’Acc-Luluse!

But in spite of all temptations to belong to other nations –

He is an Englishman! - W.S. Gilbert, “HMS Pinafore”

We have observed in this space before that saying one is Sorry has become an empty ritual. Gordon Brown has moved a few spaces ahead on the game board now, having his interlocutors say it for him, while he sits squirming in the European parliament.

The Prime Minister has not had a good week. Fresh from being publicly dressed down by MP Dan Hannan – in a YouTube clip that has circled the globe – for having spent the British nation’s patrimony in an attempt to find the bottom of a bottomless pit, Mr. Brown may have thought he could save face by sharing the stage with another head of state.

Imagine Mr. Brown’s surprise when, seated alongside him, Brazilian President Luiz Inacio Lula da Silva said “This crisis was caused by the irrational behavior of white people with blue eyes, who before the crisis appeared to know everything, and now demonstrate that they know nothing.”

This is not a Che-T-shirt-wearing college radical, not upagainstthewall.org, not Reverend Al Sharpton. This is the head of state of a nation boasting one of the world’s largest economies. There is tremendous anger in the world, not all of it being expressed by groups as feckless as the US Congress. We fear that we must now add this to the list of Things Which Will End Badly.

Moshe Silver

Chief Compliance Officer

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03/30/09 11:44 AM EDT

More Capacity Comes Out of Home Furnishings Industry

I’ve always
thought of dot.com as both a big risk and a big opportunity for the likes of
Bed, Bath and Beyond. On one hand, virtually every item at a home goods store
can be purchased online with little to no risk of getting the wrong size. In
contrast, an apparel company can do dot.com to a lesser degree as there is
some, but not massive, variability in sizing. At the extreme is footwear, where
one SKU x 3 colors x 28 different sizes = massive complexity. This gives BBBY
an edge vs. these other categories.

But within the
home goods category the edge is less clear. Specifically, the barriers to entry
are extremely low, as just about everything at a Bed Bath can otherwise be
ordered at any of hundreds of sites, and shoppers can price shop using shopping
bots. The key here for BBBY is to exploit its leverage and be sharp on price
points while upselling the consumer on impulse-purchase items.

This is working to
a degree, as Home Décor Products Inc, an on-line retailer and operator of nine
sites that sell home furnishings, ceased operations. The company is one of the
largest online home products retailers ranking number 143 in the Internet
Retailer Top 500 Guide and generated sales just shy of $100mm. This is only a
drop in the bucket to BBBY (BBBY’s revs are $7.2bn in a $110bn category), but
it is still capacity removed from the industry.On the margin, a good thing for BBBY.

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Hedgeye CEO Keith McCullough handpicks the “best of the best” long and short ideas delivered to him by our team of over 30 research analysts across myriad sectors.

The first part of this call has to play out in order for the second part to – that’s why I made it a two part call. With the price of oil up for the last 6 weeks, consecutively, taking it +42% over that time period and +15% for 2009 YTD, we are already getting what we were looking for.

Obviously copper prices being +25% for 2009 to-date supports the same. As does the SP500 trading +8% so far for March to-date, reflating +5% from the November 20th low, and +18% from the March 9th low.

A lot of market pundits confuse the terms reflation and inflation – they are not the same thing. Reflation can occur on a day-over-day and/or a month-over-month basis. All reflation means is a sequential acceleration in the price of whatever you are measuring. I measure inflation on a year-over-year price change basis.

Issuing massive liquidity like the US Government has, in the end, will be inflationary. In between now and whenever we see inflation pick up on year-over-year basis (I think we could see that more obviously in Q1 of 2010), we’ll see 2-year yields on US Treasuries rise. They should effectively start discounting what it is that we are going to see on the inflation front, no matter how many Treasury bonds Bernanke says he’s going to buy.

At ZERO percent, rates in the USA are as low as they can go. The only place they can go from here (provided that we don’t turn this place into a Japan) is UP. Rates on 2-year Treasuries are already moving to higher intermediate term highs. An important line in the sand for 2-year yields is the intermediate TREND line at 0.88%. Trading above that line is where I’ll start to concede that reflation is running higher/faster. Trading below that line is where we should all be worried about deflation.

Queen Mary better turn higher, or deflation will have us all resorting to the unenviable investment position of having to pray. Reflation is the only way out of this mess.

Keith R. McCulloughCEO / Chief Investment Officer

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03/30/09 08:23 AM EDT

CROX: The Cash Flow Keeps Drawing Me To This Name

With a maturity date of April 2, this Thursday, the deadline for Crocs to amend its credit facility is looming. Under the current agreement, the company has $22.4mm in borrowings, which is due Thursday if the company is unable to secure a new facility. It ended the year with $52mm in cash, so CROX will have had to burn through more than half of this during the quarter to risk not having enough cash on hand to fund its debt service. (Note: I wonder if the Bill and Melinda Gates Foundation – which owns at least 3.6% of shares outstanding – will let the company go under due to a near-term inability to fund short-term debt?)

Here’s how I look at it. I’m not saying that Crocs is a growth company. In fact, let’s assume the opposite. Let’s say that either the new CEO or a strategic buyer scoops up this company, takes the top line from the $847mm peak down to a core of $400mm and runs at a 10% margin (I can defend this rate six ways til Sunday). That suggests about $42mm in EBITDA. With no store openings, Crocs can sustain itself on $10-15mm/yr in capex – so we’re looking at about $25-$30mm in free cash.

At $1.19 we’re looking at an EV of $69.2mm. Do the math…the midpoint of the implied free cash flow ($27.5mm) suggests that internally generated cash flow can pay for the company in 2.5 years.

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03/30/09 08:12 AM EDT

Tough To Beat

"I'm aware if I'm playing at my best I'm tough to beat. And I enjoy that."-Tiger Woods

As
the sun was setting at Bay Hill in Orlando, Florida last night, one of
America's finest leaders reminded us that winning is ultimately born
out of adversity. After reconstructive knee surgery and a 16 foot
birdie putt sinking on the 18th, Tiger Woods is already back with a PGA
Tour win. Leaning on his bad knee, Woods didn't ask for a bailout of
that 17th hole bunker - he's an American who proactively prepares - and
man is he tough to beat!

Unfortunately, the young men on the
Yale Hockey team weren't so fortunate, but they learned an important
life lesson in Bridgeport, CT on Friday night - if you want to win at
the highest level, you have to be playing at your best. That's what
this globally interconnected marketplace is demanding from us every day
- these markets wait for no one. Winners and losers emerge every day.

The
US stock market has proven that risk managers and traders alike have
had ample opportunity to prove themselves to their investors in the
last 2 months. At +11% for March to-date, the SP500 is UP as much as it
was DOWN in February. Who has the winning strategy that can earn an
absolute return in both up and down markets? The YouTubes are on, and
we will most certainly see...

Friday's US stock market weakness
was mostly price driven. This is no surprise - this market trades on
price, not valuation. On a day-over-day basis, volume was down -32%
versus that which we saw trade into Thursday's 3-week highs. After a
+23% trough-to-peak squeezing of the Depressionistas temples, there was
(and continues to be) plenty of room for US stock prices to deflate.
Inclusive of Friday's -2% loss, the SP500 is still up a very relevant
+20.6% from its March 9th low of 676.

Where are we headed next?
Lower. While the Nasdaq is still trading +3% above what I call the
intermediate TREND line (I am long QQQQ), the SP500 failed to hold its
head above hers (827). With the Dow (I am short DIA) and the US
Financials (XLF) broken from a TREND perspective, Tech and Consumer
Discretionary can only carry this market on their backs for so long.

We
sold most of our Tech names in our virtual portfolio into Goldman
getting amped up on the semis on Thursday. Some of what Rebecca Runkle
calls "Tech Spec" was re-flating too expeditiously (Monster Worldwide
(MWW), Red Hat (RHT), etc...), so we sold those as well. No, there are
no rules against buying them back! While the XLK (Tech) is +3% for 2009
to-date, and we are still long the ETF in our Asset Allocation
Portfolio, it's not going to be a winner every day. Everything has a
time and a price.

There are 3 out of 9 sectors in the S&P
that are bullish on both an immediate term TRADE and longer term TREND
basis: Consumer Discretionary (XLY), Basic Materials (XLB), and Tech
(XLK). No these aren't themes - these are quantifiable TRENDs that
story tellers start to build investment themes around. The most obvious
one that all of three of these sectors have in common is that they are
what most investors recognize as "Early Cycle" stocks.

In this
2009 global market battle, being early is a heck of a lot better than
being late. The old "event driven" momentum model of the levered long
days has rendered the Fast Money strategy of buying high to "sell
higha" somewhat useless. What we want to be doing here in a Bear market
is simply buying low (early), and selling high (late). The strategy has
been around for centuries, it's actually not that complicated.

What
is complicated is understanding why President Obama let Timmy Geithner
out of this room yesterday. On a busy market day, it's hard enough to
trust his mug while it's on television, never mind when thought leaders
in this country can actually take the time on a Sunday to listen to
what this man is actually saying. I'll let the media get you up to
speed on what he said specifically, but I can assure you of this - the
world doesn't trust this guy as far as Rick Wagoner can throw him.

Away
from Obama throwing out the embattled CEO of GM overnight, the global
economic community seems perfectly happy to toss whatever they owned
for a Bear market TRADE right back under the bus this morning. As
Geithner moves to try selling Americans on "Cash for Trash", most of us
are cool with tucking our very own hard earned cash under our beds and
hoping that his days leading this country out of this financial mess
are soon over...

Hope, of course, is not an investment process.
Neither is betting against the true American leaders in this country,
like Tiger Woods. In a world where everyone who won't exist without a
bailout is whining for more easy money leverage - it's time to start
looking in the mirror and focusing on winning without the foot wedge.
Play by gentleman's rules and do whatever it is that you need to do to
get that win on the tape - because no matter where you go out there
today, there those marked-to-market scores will be.

Always be
at your best - stay hedged - and always make your portfolio structure
tough for Big Government to beat. My downside support levels for the
SP500 are 801, then 760. Manage risk (or trade) around those levels
proactively.

Best of luck out there fighting the good fight today,KM

LONG ETFS

RSX - Market Vectors Russia-The
Russian macro fundamentals line up with our quantitative view on a
TREND duration. Oil has benefited from the breakdown of the USD, which
has buoyed the commodity levered economy. We're seeing the Ruble
stabilize and are bullish Russia's decision to mark prices to market,
which has allowed it to purge its ills earlier in the financial crisis
cycle via a quicker decline in asset prices. Russia recognizes the
important of THE client, China, and its oil agreement in February with
China in return for a loan of $25 Billion will help recapitalize two of
the country's important energy producers and suppliers.

QQQQ - PowerShares NASDAQ 100 -
We bought QQQQ on Wednesday (3/25) on the pullback. We believe the
NASDAQ has moved into a very bullish tradable range and is breaking out
from an intermediate TREND perspective alongside the more Tech specific
XLK etf.

USO - Oil Fund-
We bought oil on Wednesday (3/25) for a TRADE and are positive on the
commodity from a TREND perspective. With the uptick of volatility in
the contango, we're buying the curve with USO rather than the front
month contract.

EWC - iShares Canada-We
bought Canada on Friday (3/20) into the selloff. We want to own what
THE client (China) needs, namely commodities, as China builds out its
infrastructure. Canada will benefit from commodity reflation,
especially as the USD breaks down. We're net positive Harper's
leadership, which diverges from Canada's large government recent
history, and believe next year's Olympics in resource rich Vancouver
should provide a positive catalyst for investors to get long the
country.

XLK - SPDR Technology-Technology
looks positive on a TRADE and TREND basis. Fundamentally, the sector
has shown signs of stabilization over the last several weeks.
Semiconductor stocks, which are early cycle, have provided numerous
positive data points on the back of destocking in the channel and
overall end demand appears to be stabilizing. Software earnings from
ADBE and ORCL were less than toxic this week and point to a "less bad"
environment. As the world stabilizes, M&A should pick up given
cash rich balance sheets in this sector and an IBM/JAVA transaction may
well prove the catalyst to get things going.

EWA - iShares Australia-EWA
has a nice dividend yield of 7.54% on the trailing 12-months. With
interest rates at 3.25% (further room to stimulate) and a $26.5BN
stimulus package in place, plus a commodity based economy with
proximity to China's H1 reacceleration, there are a lot of ways to win
being long Australia.

GLD - SPDR Gold- We bought gold on a down day. We believe gold will re-assert its bullish TREND.

UUP - U.S. Dollar Index -
We believe that the US Dollar is the leading indicator for the US stock
market. In the immediate term, what is bad for the US Dollar should be
good for the stock market. The Euro is down versus the USD at $1.3169.
The USD is down versus the Yen at 96.7600 and up versus the Pound at
$1.4119 as of 6am today.

XLI - SPDR Industrials- We shorted it on 3/26; industrials remain broken on a TREND basis.

EWL - iShares Switzerland -
We shorted Switzerland for a TRADE on an up move Wednesday (3/25) and
believe the country offers a good opportunity to get in on the short
side of Western Europe, and in particular European financials.
Switzerland has nearly run out of room to cut its interest rate and due
to the country's reliance on the financial sector is in a favorable
trading range. Increasingly Swiss banks are being forced by governments
to reveal their customers, thereby reducing the incentive of
Switzerland as a tax-free haven.

LQD - iShares Corporate Bonds-
Corporate bonds have had a huge move off their 2008 lows and we expect
with the eventual rising of interest rates in the back half of 2009
that bonds will give some of that move back. Moody's estimates US
corporate bond default rates to climb to 15.1% in 2009, up from a
previous 2009 estimate of 10.4%.

EWJ - iShares Japan -
Into the strength associated with the recent market squeeze, we
re-shorted the Japanese equity market rally via EWJ. This is a tactical
short; we expect the market there to pull back when reality sinks in
over the coming weeks. Japan has experienced major GDP contraction-it
dropped 3.2% in Q4 '08 on a quarterly basis, and we see no catalyst for
growth to return this year. We believe the BOJ's recent program to
provide $10 Billion in loans to repair banks' capital ratios and a plan
to combat rising yields by buying treasuries are at best a "band aid". EWU - iShares UK
-The UK economy is in its deepest recession since WWII. We're bearish
on the country because of a number of macro factors. From a monetary
standpoint we believe the Central Bank has done "too little too late"
to manage the interest rate and now it is running out of room to cut.
The benchmark currently stands at 0.50% after a 50bps reduction on 3/5.
While the Central Bank is printing money and buying government
Treasuries to help capitalize its increasingly nationalized banks, the
country has a considerable ways to go to attain its 2% inflation
target. Unemployment is on the rise, housing prices continue to fall,
and the trade deficit continues to steepen month-over-month.

EWW - iShares Mexico-
We're short Mexico due in part to the country's dependence on export
revenues from one monopolistic oil company, PEMEX. Mexican oil exports
contribute significantly to the country's total export revenue and
PEMEX pays a sizable percentage of taxes and royalties to the federal
government's budget. This relationship is unstable due to the
volatility of oil prices, the inability of PEMEX to pay down its debt,
and the fact that PEMEX's crude oil production has been in decline
since 2004 and is down 10% YTD. Additionally, the potential
geo-political risks associated with the burgeoning power of regional
drug lords signals that the country's economy is under serious duress.

IFN -The India Fund-
We have had a consistently negative bias on Indian equities since we
launched the firm early last year. We believe the growth story of
"Chindia" is dead. We contest that the Indian population, grappling
with rampant poverty, a class divide, and poor health and education
services, will not be able to sustain internal consumption levels
sufficient to meet targeted growth level. Other negative trends we've
followed include: the reversal of foreign investment, the decrease in
equity issuance, and a massive national deficit. Trade data for
February paints a grim picture with exports declining by 15.87% Y/Y and
imports sliding by 18.22%.

XLP - SPDR Consumer Staples-Consumer Staples was the best sector on Friday (3/27), showing that low beta can actually work on a down day!

SHY - iShares 1-3 Year Treasury Bonds-
On 2/26 we witnessed 2-Year Treasuries climb 10 bps to 1.09%. Anywhere
north of +0.97% moves the bonds that trade on those yields into a
negative intermediate "Trend." If you pull up a three year chart of
2-Year Treasuries you'll see the massive macro Trend of interest rates
starting to move in the opposite direction. We call this chart the
"Queen Mary" and its new-found positive slope means that America's cost
of capital will start to go up, implying that access to capital will
tighten. Yield is inversely correlated to bond price, so the rising
yield is bearish for Treasuries.

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Daily Trading Ranges

20 Proprietary Risk Ranges

Daily Trading Ranges is designed to help you understand where you’re buying and selling within the risk range and help you make better sales at the top end of the range and purchases at the low end.

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